1984 (8) TMI 78

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....ered by JAGANNATHA SHETTY J.-The question referred by the Income-tax Appellate Tribunal, Bangalore Bench, is: " Whether, on the facts and in the circumstances of the case, the income of the trust was exempt under section 10(22A) of the Act ? " The assessee-trust was constituted by a deed dated March 17, 1973. The object of the trust, among others, was to provide medical relief to the need....

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....that since the assessee had just a dispensary, it was not entitled to the exemption under s. 10(22A) of the Act. Section 10(22A) of the Act reads: " 10. In computing the total income of a previous year of any person, any income falling within any of the following clauses shall not be included- . ...... (22A) any income of a hospital or other institution for the reception and treatment of ....

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....y one of public or general utility. In the context in which "other institution " occurs in s. 10(22A), it must mean an organisation or undertaking established solely for philanthropic purposes and to cater to the needs of persons suffering from illness or treatment of persons during convalescence or requiring rehabilitation. According to the Tribunal, " hospital or other institution " referred ....